Code of Corporate Ethics

This Code of Corporate Ethics is designed to establish a standard of conduct to be followed by every officer and employee of Tsubaki Group companies. Appropriate ethical behaviors support the foundation of our business activities and therefore all officers and employees are required to strive to establish corporate ethics and innovate corporate culture in compliance with this Code of Corporate Ethics.

1. Basic stance

(1) Compliance with laws and regulations

We will comply with all laws and regulations of all countries where we conduct business in addition to our internal rules. We will respect international norms, and also take into consideration culture, practices, traditions, and religion.

(2) Faithful and fair business activities

ⅰ. Our activities shall contribute to sustainable economic growth and resolution of social issues.

ⅱ. We will not engage in any act that should be socially criticized or is unexplainable to outsiders, even if it is not in violation of any law or regulation.

2.Business activities

(1) Relationships with customers and partners

ⅰ. In order to ensure customer satisfaction, we will develop and provide safe and high-quality products and services through innovation, and maintain and improve the reputation of “Tsubaki brand” developed by our predecessors.

ⅱ. We will ensure appropriate transactions and responsible procurement based on free and fair competition.

ⅲ. In order to eliminate acts of corruption and fraud, our activities of entertainment, gift-giving and invitation will be conducted with restraint, in compliance with applicable laws and regulations, and within the scope of social common sense. In particular, we will not offer entertainment, gift or invitation to domestic and foreign public officials in violation of any law or regulation of the country or region concerned.

(2) Relationships with shareholders and investors

ⅰ. Proper disclosure of information
We will ensure highly transparent business management through timely and proper disclosure of various information and enhance our corporate value through constructive dialogue.

ⅱ. Fair and proper accounting treatment
We will ensure appropriate accounting treatment and accurate report on operating results in accordance with fair and proper accounting principles.

ⅲ. Prohibition of insider trading
We will not engage in insider trading by any means.

(3) Relationships with employees

ⅰ. Respect for basic human rights
Human rights of employees will be respected and no discrimination or harassment will be made for reasons of race, creed, gender, age, nationality, religion, disability or otherwise.
Child labor, forced labor and any other unjust labor practices will not be allowed.

ⅱ. Maintenance of good industrial relations
We will maintain good industrial relations in compliance with all applicable labor laws and regulations. Personnel evaluation will be made in a fair and persuasive manner.

ⅲ. Focus on diversity and provision of safe and comfortable working environments
We will promote work practices that will improve the capability of employees and that respect their diversity, character, and personality. We will also respect creativity of our employees and ensure safe and comfortable working environments to help them to realize their full potential.

(4) Relationships with society

ⅰ. Environmental protection
We will enhance our efforts in environmental issues, reduce our impact on environment and contribute to protection of global environment.

ⅱ. Contribution to society
We will actively engage in social contribution activities as a good corporate citizen and with recognition that every company is a member of society.

ⅲ.Thorough crisis management
We will conduct thorough and organized crisis management in the face of actions by antisocial forces, terrorism, cyber attacks, natural disasters and other crises that pose a threat to civil society and corporate activity.

3. Standards of daily behavior

(1) Clarification of responsibility

We will ensure speedy management through role sharing and clarification of responsibility in our business activities.

(2) Strict management of information

ⅰ. Confidential information
All information relating to our business activities shall be recognized as important corporate property and accordingly, shall be strictly managed in accordance with our internal rules.

ⅱ. Personal information
Personal information and confidential information of our customers and partners shall be obtained, if any, in due manner, used only within the specified scope, and appropriately managed in compliance with laws, regulations and our internal rules.

(3) Protection of corporate property

We will endeavor for protection of our products, intellectual properties, machinery equipment, devices, fixtures and other corporate property, tangible or intangible, without using any of them for private or other unauthorized purposes.

(4) Prohibition of conflict of interests

We are prohibited from doing any act that may infer a conflict between personal and corporate interests and from pursuing personal interest in disguise of business activities.

4. Operational and compliance systems

(1) Officers’ leadership and employees’ self-discipline

Officers are required to take the leadership in complying with, and disseminate this Code of Corporate Ethics. Employees are required to discipline themselves as a member of our Company. Our supply chains shall be also encouraged to act based on the principles of this Code of Corporate Ethics.

(2) Helpline

An ethics helpline is established within the organization of Tsubakimoto Chain Co. (“Ethics Helpline”) to serve as a consultation service desk of the Tsubaki Group to advise on a behavior or decision-making in compliance with this Code of Corporate Ethics. Operation rules of the Ethics Helpline will be separately specified to clearly set forth consultation procedures, how to solve issues and prohibition of unfavorable treatment of persons consulting with the helpline.

(3) Duty of consultation

Any person who is aware of any act that is or is suspected to be in violation of this Code of Corporate Ethics shall promptly consult with the Ethics Helpline established under the preceding subparagraph. No person will be treated unfavorably for consulting with the Ethics Helpline.

(4) Measures against violation

The Ethics Committee will take strict measures as necessary against any violation of this Code of Corporate Ethics.

(5) Governing body

This Code of Corporate Ethics shall be governed by ethics officials in the legal department of Tsubakimoto Chain Co.

(6) Procedures for establishment, revision and repeal

Procedures for establishment, revision and repeal of this Code of Corporate Ethics shall be determined by the Board of Directors.

Established: November 20, 2002
Revised: April 1, 2022

Toward a Sustainable Society

The Tsubaki Group is engaged in the “art of moving” and aims to provide value that exceeds expectations
to become a company that continues to be needed by society.